Sunnyland Neighborhood Association Odor Presentation

January 15, 2008

NWCAA Programs & Services

• Public information & education

• Asbestos

• Indoor Air

• Air Monitoring

• New Source Review

• Air Operating Permit Program

• Small Business Assistance

• Global Climate Change

• Outdoor Burning & Agricultural Burning

• Woodstoves

• Complaint Response & Enforcement

Overview of Topics:

NWCAA Odor RegulationsSection 535 – Odor Control Measures

535.3 - Any person who shall cause or allow the generation of any odor from any source which may unreasonably interfere with any other property owner’s use and enjoyment of his or her property must use recognized best practices and control equipment to reduce these odors to a reasonable minimum.

• Complaint driven

• NWCAA investigates

Impact must be “unreasonable”

Impact must occur at person’s place of residence or work

Source of odor confirmed

Best practices/control

• Enforcement action if nuisance odors are confirmed by field staff

• Odor presence does not always = violation

• Person must be willing to testify if necessary

NWCAA Odor Regulations

Section 535 – Odor Control Measures (cont.)

535.4 - Odor emissions detrimental to persons or property. No person shall cause or permit the emission of any odorous air contaminant from any source if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business.

• Emissions “detrimental”

• Specifically references “welfare”

Registering a Complaint • Citizen files complaint with the NWCAA (by phone for odors) at

the time of impact or ASAP

• Information should include:

Complainant’s name, address, and phone number

Time and date

Location of impact

Description of impact

Characteristic and duration of odor

Any other pertinent information (i.e. wind direction)

• Complainant willing to testify to unreasonable impact if necessary (enforcement action appealed)

Note: Complaints referencing odors not at their residence or place of work will be considered FYI only

Complaint Response Process

• Impacted person files complaint with NWCAA

• Inspector investigates in appropriate manner

NWCAA contacts complainant for additional

information if necessary

Potential odor source(s) contacted by inspection staff

Site investigation of potential odor source(s)

conducted by NWCAA when appropriate

• Formal enforcement action may be initiated by NWCAA if nuisance odors are confirmed by field staff

Enforcement Process

Goal is compliance

• “Violation” formally documented

• Requires source to respond with corrective action

• Allows for the imposition of penalties as incentive for compliance

• Portion of penalty may be suspended if facility commits to mitigation steps

Odor Complaint History

Influences on Odor Levels & Complaints

• Meteorology

Mixing of emissions

Odor “pockets”

• Topography – Ohio/Iowa St. area

• Multiple odor sources

• Public awareness

Topography Map – Zoom In

NWCAA – Odor Area Survey Purpose:

• Identify potential odor sources

Identified three types of source categories Spray coaters (12+)

Coffee roaster (2)

Wood treater (1)

• Work with facilities with larger odor potential:

Evaluate overall emissions

Reduce odors

• Work with remaining sources:

Evaluate overall emissions

Reduce odors

Potential Odor Sources - ListFacility Name Address

Process Equipment

Facility Name Address

Process Equipment

Boulevard Customs 2227 Queen St.

Spray booth - Auto body painting

Moka Joe's Coffee 2118 James St. RoasterGrand Central Collision, Inc. 1811 Iowa

Spray Booth - Auto body painting

Three Sun's Roasting Company 2209 Queen St. Roaster 20/20 Customs 2145 Queen St.

Spray Booth - Auto body painting

Haskell Corporation 1001 Meador Ave

Spray booth for finishing, lacquer

Olsen Auto Body & Collision 1919 Humbolt St.

Spray Booth - Auto body painting

Price and Visser 2207 Valencia St.Paint Booth - Doors, cabinets

Custom Design & Awning (CDI) 423 Kentucky Spray Booth

Al's I-5 RV Inc 2039 Moore St.

Minor painting with spray cans - touch-up Final Finish 611 Kentucky

Spray Booth - Auto (touch-up bumpers)

Diehl's Collision Center 1820 James St.

Spray Booth - Spray coating cars

Bellingham High School 2020 Cornwall

Three-sided Spray Booth

Windsor Plywood 2119 Queen St.Spray Booth - Lacquer

Brooks Manufacturing Company 2120 Pacific St.

Lumber treating facility specializing

Tero Company 2127 Lincoln St.Spray Booth - Lacquer

Pearson Construction 2034 Franklin St.

Staining, Some minor painting at night

Steve Hall Woodworking 2139 Humbolt

Spray Booth - Lacquer Chuck's Shop 1830 Grant St.

Another owner suggested painting at

Towne Painting Co. 2116 Queen St.

Spray Booth - Lacquer Northwest Honda 2010 Iowa

Mobile Repair Unit On-Site

Greg Aanes 2109 Queen St.Spray Booth - Lacquer

- Veteran's Autobody  

Mobile Repair of bumpers w/spray guns

Bellingham Collision Repair 2034 Moore St.

Spray Booth - spray coating cars

Pro-tent & Pro-deal 1400 Kentucky

Possible touch-up painting

Potential Odor Sources Identified

NWCAA’S Actions2003

•Windsor Plywood issued Notice of Violation (NOV) for odor

2006

• Canvassed industrial odor sources in the Iowa/Ohio areas to identify potential odor sources

• Enhanced complaint investigation to include after-hour response

• Issued NOV warning to Brooks for odor nuisance

2007

• Further enhanced complaint investigation to include additional after-hour response

On-going:

•Work with facilities to address odor mitigation efforts

Examples of Facility Modifications

Windsor Plywood

• Changed out high-emission spray guns to low-emission spray guns

• Increased spray booth exhaust stack height

• Operational changes

Examples of Facility Modifications

Brooks Manufacturing 2006• Enclosed east side of treated material storage

area

• Piloted “odor neutralizer” project

• Installed meteorological station

2007• Installed water spray on exhaust stack to

reduce emissions

• Installed 1st set of odor control devices (activated carbon) on process exhaust stack

Examples of Facility Modifications

Brooks Manufacturing - 2007 (cont.)

• Installed 2nd set of odor control devices (activated carbon) on process exhaust stack

• Installed odor control device waste water system (activated carbon)

• Covered open-top tanks

• Installed balancing system on “work” tanks to reduce emissions

• Increasing frequency of carbon change-out to once/month (formerly quarterly)

Examples of Facility Modifications

• Install odor control devices (activated carbon) on tank vents, including delivery tank

• To fully enclose treated material storage and install automatic hangar doors

• Increase exhaust stack height and diameter

• Install and ID fan on control device

Brooks Manufacturing - 2008

On-going NWCAA Actions

• Continue to work with facilities to address nuisance odor mitigation efforts

• Continue to respond to complaints, including after-hours when needed

• Explore hiring third-party consultant to conduct odor survey

• Work with City of Bellingham Planning Department

Citizen Follow-up

• File a complaint with NWCAA

Information should include:

• Complainant’s name, address, and phone number

• Time and date

• Location of impact

• Description of impact

• Characteristic and duration of odor

• Any other pertinent information (i.e. wind direction)

• Complainant willing to testify if necessary

• Identify person(s) to tour Brooks facility

Contact Information

800.622.4627 (Whatcom & Island county)

360.428.1617 (Skagit County)

info@nwcleanair.org

www.nwcleanair.org